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FINRA Orders Four Firms to Pay $2.6 Million for Violations Relating to Fully Paid Securities Lending

FINRA announced today that it has sanctioned four firms—M1 Finance LLC, Open to the Public Investing, Inc., SoFi Securities LLC, and SogoTrade, Inc.—a combined $2.6 million, including over $1 million in restitution to retail customers enrolled in fully paid securities lending programs and fines of $1.6 million for the firms’ related supervisory and advertising violations.

2021069375901 The Windmill Group, Inc. CRD 8384 AWC gg (2024-1704413997545).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2021069375901 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: The Windmill Group, Inc. (Respondent) Member Firm CRD No. 8384 Pursuant to FINRA Rule 9216, Respondent The Windmill Group, Inc. submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2021072127801 SogoTrade Inc. CRD 17912 AWC gg (2024-1704413997707).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2021072127801 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: SogoTrade, Inc. (Respondent) Member Firm CRD No. 17912 Pursuant to FINRA Rule 9216, Respondent SogoTrade, Inc. submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2021072127701 Open to the Public Investing, Inc. CRD 127818 AWC gg (2024-1704413997582).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2021072127701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Open to the Public Investing, Inc. (Respondent) Member Firm CRD No. 127818 Pursuant to FINRA Rule 9216, Respondent Open to the Public Investing, Inc. submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2021072127101 SoFi Securities LLC CRD 151717 AWC gg (2024-1704413997623).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2021072127101 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: SoFi Securities LLC (Respondent) Member Firm CRD No. 151717 Pursuant to FINRA Rule 9216, Respondent SoFi Securities LLC submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2022073818801 William W. Godfrey CRD 2447660 AWC gg (2024-1704413997575).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2022073818801 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: William Wade Godfrey (Respondent) General Securities Representative CRD No. 2447660 Pursuant to FINRA Rule 9216, Respondent William Wade Godfrey submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FPI230003 Securities Capital Corporation CRD 22892 Expedited Decision df (2024-1704413997456).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. SECURITIES CAPITAL CORPORATION (CRD No. 22892), Respondent. Expedited Proceeding No. FPI230003 STAR No. 20230790019 Hearing Officer–BEK EXPEDITED HEARING PANEL DECISION October 5, 2023 For failing to file its annual audit report, Respondent is suspended, assessed a $1,000 late fee, and ordered to pay costs.

DFC230002 Arque Capital Ltd CRD 121192 Expedited Decision df (2024-1704413997340).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. ARQUE CAPITAL, LTD. (CRD No. 121192), Respondent. Expedited Proceeding No. DFC230002 STAR No. 20230793367 Hearing Officer–BEK EXPEDITED DECISION December 1, 2023 Respondent Arque Capital, Ltd., failed to pay FINRA dues, fees, and other charges. Accordingly, its membership is cancelled. Appearances For the Complainant: Michael Manning, Esq., Mark Fernandez, Esq., and Jennifer L.

ARB230012 John Knox Goodwin CRD 712634 Expedited Decision df (2024-1704413997550).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. JOHN KNOX GOODWIN (CRD No. 712634), Respondent. Expedited Proceeding No. ARB230012 STAR No. 20230791661 Hearing Officer—MJD EXPEDITED DECISION October 4, 2023 Respondent failed to pay a $24,000 arbitration award and failed to prove that he had a bona fide inability to pay or make a meaningful payment toward the award. Respondent is therefore suspended from associating with any FINRA member in any capacity. Appearances For the Complainant: Michelle Galloway, Esq., Michael P.

2022076975901 Miche D Jean CRD 5918186 Default Decision df (2024-1704413997608).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. MICHE D. JEAN (CRD No. 5918186), Respondent. Disciplinary Proceeding No. 2022076975901 Hearing Officer–DRS DEFAULT DECISION June 27, 2023 Respondent is barred from associating with any FINRA member in any capacity for failing to provide information and documents and appear for on-the-record testimony that FINRA requested in connection with an investigation. Appearances For the Complainant: Matthew M. Ryan, Esq., Melissa J.